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UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA,
Plaintiff,
v.
GEORGE CHIANG,
Defendant.
CR No.
I N F O R M A T I O N
[18 U.S.C. § 1962(d): Racketeer Influenced and Corrupt Organizations Conspiracy]
The United States Attorney charges:
INTRODUCTORY ALLEGATIONS
At times relevant to this Information:
A. BACKGROUND ON CITY PROCESSES
1. All legislative power in the City of Los Angeles (the
“City”) was vested in the City Council and was exercised by ordinance
subject to a veto by the Mayor. The City was divided into fifteen
City Council Districts covering different geographic areas. The City
Council was composed of fifteen members elected from single-member
districts.
2. To prevent former City officials from exercising or
appearing to exercise improper influence over City decisions, the Los
2:20-cr-00203-PA
05/13/2020AP
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Angeles Municipal Code, Sections 49.5.1 et seq., contained “revolving
door” restrictions. The restrictions imposed a lifetime ban on
receiving compensation to attempt to influence City action on a
specific matter in which the City official personally and
substantially participated in during their City service. The
restrictions also imposed a one-year ban, or “cooling-off” period,
during which the City official was prohibited from attempting to
influence action on a matter pending before the City official’s
former City agency for compensation, regardless of participation in
that matter.
3. Within the City, large-scale development projects required
a series of applications and approvals prior to, during, and after
construction. These applications and approvals occurred in various
City departments, including the City Council, the Planning and Land
Use Management (“PLUM”) Committee, the Economic Development
Committee, the Los Angeles Planning Department, the Los Angeles
Department of Building and Safety (“LADBS”), the Area Planning
Commission, the City Planning Commission, and the Mayor’s Office.
4. Each part of the City approval process required official
actions by public officials. These included entitlements, variances,
general plan amendments, subsidies, incentives, public benefits,
scheduling agendas for the various committees, and overall approvals.
The process allowed for public hearings, feasibility studies,
environmental impact reports, and other steps in the life of
development projects.
5. Even for projects that were not going through the City
approval process, City officials could benefit, or take adverse
action against, a project by advocating for, pressuring, or seeking
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to influence other City officials, departments, business owners, and
stakeholders.
6. Developers typically hired consultants and/or lobbyists to
assist in guiding projects through the development process and City
departments, including interfacing with the City Council office that
represented the district in which the project was located.
B. RELEVANT PERSONS AND ENTITIES
7. Defendant GEORGE CHIANG was a real estate broker and
development consultant in the City. From 2006 to 2014, defendant
CHIANG was primarily engaged in property management and the sale of
residential and commercial property in the San Gabriel Valley. In
2014, defendant CHIANG established a corporation offering consulting
services under the name Synergy Alliance Advisors, Inc. (“Synergy”).
8. Councilmember A was the Councilmember for a City Council
District (“CD-A”). Councilmember A served on the PLUM Committee, a
body appointed by the City Council President that oversaw many of the
most significant commercial and residential development projects in
the City. Councilmember A also served on the Economic Development
Committee.
9. City Staffer A-1 and City Staffer A-2 worked for the City
on Councilmember A’s staff.
10. Relative A-1 was a relative of Councilmember A. Beginning
no later than 2007, Relative A-1 received a bi-weekly payment of
approximately $2,500 from Law Firm A as part of her employment with
Law Firm A tasked with marketing and business development. Between
approximately July 2012 and January 2016, Relative A-1 received
regular employment payments from High School A, totaling
approximately $150,000, as a fundraiser for the school. In or about
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September 2018, Relative A-1 formally announced her candidacy to
succeed Councilmember A as Councilmember for CD-A.
11. Councilmember A’s Associate was a close associate of
Councilmember A, and operated Company A in the City.
12. Justin Kim was a real estate appraiser and consultant for
real estate developers with projects in the City and a major
fundraiser for Councilmember A.
13. Individual 1 was the General Manager of the LADBS until in
or about May 2016. In or about May 2016, Individual 1 was appointed
by the Mayor as the City’s Deputy Mayor for Economic Development. As
Deputy Mayor, Individual 1 directed LADBS and the Planning
Department, among other City departments. In or about July 2017,
Individual 1 retired from the City and formally began working as a
consultant with defendant CHIANG at Synergy in downtown Los Angeles.
Beginning on or about August 1 2017, Individual 1 was the sole owner
of Individual 1’s Company, a real estate firm located in downtown Los
Angeles.
14. CCC Investment Group, Inc. (“CCC Investment”) was a real
estate brokerage and consulting firm created by defendant CHIANG and
Individual 1 on or around August 15, 2017.
15. Planning Commission Official was a member of the mayoral-
appointed City Planning Commission.
16. City Staffer D was a high-ranking staff member for a
councilmember in one of the City’s districts.
17. Company D was, according to its website, one of the top
real estate companies in China with projects worldwide. Company D,
through its subsidiaries, acquired a property located in CD-A in
2014, and planned to redevelop the property into a mixed-use
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development that was to include 80,000 square feet of commercial
space, 650 residential units, and 300 hotel rooms, and would be
valued at several hundred million dollars (“Project D”).
18. Chairman D was the Chairman of Company D.
19. General Manager D was the general manager of Project D
until he was terminated from that role in approximately January 2017.
20. Synergy Consultant was hired by Synergy to consult on
Project D.
21. PAC A was a political action committee formed to primarily
benefit Relative A-1’s campaign for the CD-A seat.
22. These Introductory Allegations are incorporated by
reference into the sole count of this Information.
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COUNT ONE
[18 U.S.C. § 1962(d)]
A. THE RACKETEERING ENTERPRISE
23. Defendant CHIANG and others known and unknown to the United
States Attorney, were members and associates of the CD-A Enterprise,
a criminal organization whose members and associates engaged in,
among other things, bribery, extortion, and mail and wire fraud,
including through the deprivation of the honest services of City
officials and employees, and money laundering. The CD-A Enterprise
operated within the Central District of California and elsewhere.
24. The CD-A Enterprise, including its leaders, members, and
associates, constituted an “enterprise,” as defined by Title 18,
United States Code, Section 1961(4), that is, a group of individuals
associated in fact. The CD-A Enterprise constituted an ongoing
organization whose members functioned as a continuing unit for a
common purpose of achieving the objectives of the enterprise. The
CD-A Enterprise engaged in, and its activities affected, interstate
and foreign commerce.
B. OBJECTIVES OF THE ENTERPRISE
25. The objectives of the CD-A Enterprise included, but were
not limited to, the following:
a. enriching the members and associates of the CD-A
Enterprise through means that included bribery, extortion, and mail
and wire fraud, including through the deprivation of the honest
services of City officials and employees;
b. advancing the political goals and maintaining the
control and authority of the CD-A Enterprise by elevating members and
associates of the CD-A Enterprise to, and maintaining those
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individuals’ placement in, prominent elected office, through means
that included bribery and mail and wire fraud, including through the
deprivation of the honest services of City officials and employees;
c. concealing the financial activities of the CD-A
Enterprise, through means that included money laundering and
structuring; and
d. protecting the CD-A Enterprise by concealing the
activities of its members and associates and shielding the CD-A
Enterprise from detection by law enforcement, the City, the public,
and others, through means that included obstructing justice.
C. RICO CONSPIRACY
26. Beginning on a date unknown to the United States Attorney,
but no later than January 1, 2014, and continuing to in or about
December 2018, in Los Angeles County, within the Central District of
California and elsewhere, defendant CHIANG, a person employed by and
associated with the CD-A Enterprise, conspired with others known and
unknown to the United States Attorney to unlawfully and knowingly
violate Title 18, United States Code, Section 1962(c), that is, to
conduct and participate, directly and indirectly, in the conduct of
the CD-A Enterprise’s affairs through a pattern of racketeering
activity, as that term is defined in Title 18, United States Code,
Sections 1961(1) and 1961(5), consisting of multiple acts:
a. involving bribery, in violation of California Penal
Code Sections 67 and 68;
b. indictable under Title 18, United States Code,
Sections 1341, 1343, and 1346 (Mail and Wire Fraud, including through
the Deprivation of Honest Services);
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c. indictable under Title 18, United States Code, Section
1951 (Extortion);
d. indictable under Title 18, United States Code, Section
1952 (Interstate and Foreign Travel in Aid of Racketeering
Enterprises);
e. indictable under Title 18, United States Code,
Sections 1956 and 1957 (Money Laundering);
f. indictable under Title 18, United States Code, Section
1512 (Obstruction of Justice and Witness Tampering); and
g. indictable under Title 31, United States Code, Section
5324 (Structuring Transactions to Evade Reporting Requirement).
27. It was a further part of the conspiracy that defendant
CHIANG agreed that a conspirator would commit at least two acts of
racketeering activity in the conduct of the affairs of the
enterprise.
D. MEANS BY WHICH THE OBJECT OF THE CONSPIRACY WAS TO BE
ACCOMPLISHED
28. Defendant CHIANG and other members and associates of the
CD-A Enterprise agreed to conduct the affairs of the CD-A Enterprise
through the following means, among others:
a. In order to enrich its members and associates, the CD-
A Enterprise operated a pay-to-play scheme within the City of Los
Angeles, wherein public officials demanded financial benefits from
developers and their proxies in exchange for officials acts.
Specifically, through a scheme that involved bribery, mail and wire
fraud, and extortion, Councilmember A, City Staffer A-1, Individual 1
and other City officials demanded, solicited, accepted, and agreed to
accept from developers and their proxies, including defendant CHIANG,
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some combination of the following types of financial benefits, among
others: (1) cash; (2) consulting and retainer fees; (3) favorable
loans; (4) casino chips at casinos; (5) flights on private jets and
commercial airlines; (6) stays at luxury hotels; (7) expensive meals;
(8) spa services; (9) event tickets to concerts, shows, and sporting
events; (10) escort and prostitution services; and (11) other gifts.
b. In exchange for such financial benefits from
developers and their proxies, Councilmember A, City Staffer A-1,
Individual 1 and other City officials agreed to perform and performed
the following types of official acts, among others: (1) filing
motions in various City committees to benefit projects; (2) voting on
projects in various City committees, including the PLUM Committee,
and City Council; (3) taking, or not taking, action in the PLUM
Committee to expedite or delay the approval process and affect
project costs; (4) exerting pressure on other City officials to
influence the approval process of projects; (5) negotiating with and
exerting pressure on labor unions to resolve issues on projects; (6)
exerting pressure on developers with projects pending before the City
to affect their business practices; and (7) taking official action to
enhance the professional reputation and marketability of
businesspersons in the City.
c. In order to protect and hide the financial payments
that flowed from the developers and their proxies to the public
officials, the CD-A Enterprise engaged in money laundering and other
activities to conceal monetary transactions and bribe payments.
Specifically, members and associates of the CD-A Enterprise engaged
in the following activities, among others: (1) storing large amounts
of cash in one’s residence; (2) providing cash to family members and
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associates; (3) directing payments to family members, associates, and
entities to avoid creating a paper trail between the developers,
their proxies and public officials; (4) using family members and
associates to pay expenses; (5) depositing cash at ATMs and banks in
amounts under $10,000 to avoid bank reporting requirements; and (6)
failing to disclose payments and benefits received on Form-700s and
on tax returns.
d. In order to maintain its power and control, members
and associates of the CD-A Enterprise used their positions and
relationships to illicitly ensure a political power base filled with
only their allies and to monopolize significant official City
positions, resources, and financial support. Specifically, through
bribery, members and associates of the CD-A Enterprise raised funds
from developers and their proxies with projects in CD-A for the
following, among others: (1) Councilmember A’s re-election campaigns
and officeholder accounts; (2) Relative A-1’s election campaign for
the CD-A seat; (3) Political Action Committees formed purportedly to
benefit a broad array of candidates and causes but, in fact, utilized
to benefit Relative A-1’s election campaign.
e. In order to protect the CD-A Enterprise and avoid
detection by law enforcement, the City, the public, and others,
members and associates of the CD-A Enterprise engaged in the
following types of obstructive conduct: (1) lying to law enforcement
in an effort to impede the investigation into criminal conduct of the
CD-A Enterprise; (2) attempting to corruptly influence the statements
of others to law enforcement; and (3) using encrypted messaging
applications, including those utilizing a self-destructing message
system, to communicate about the affairs of the CD-A Enterprise.
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E. OVERT ACTS
29. In furtherance of the conspiracy and to accomplish the
object of the conspiracy, on or about the following dates, defendant
CHIANG and others known and unknown to the United States Attorney,
committed and caused to be committed various overt acts within the
Central District of California, and elsewhere, including the
following:
PROJECT D BRIBERY SCHEMES
30. Between November 2014 and November 2018, Councilmember A
solicited financial benefits from Company D, including from Chairman
D, General Manager D, and its consultants (defendant CHIANG and
Individual 1), in exchange for Councilmember A’s official acts to
benefit Project D. In exchange for official acts from
Councilmember A to benefit Project D, defendant CHIANG, Chairman D,
General Manager D, and Individual 1 agreed to facilitate and provide
financial benefits to Councilmember A, including $66,000 in
consulting fees to a Councilmember A’s Associate, a trip to China for
Councilmember A and his family, event tickets, expenses, and a
$100,000 contribution to PAC A to benefit Relative A-1’s campaign for
the CD-A seat.
31. Between January 2017 and June 2017, while Individual 1 was
a Deputy Mayor, defendant CHIANG and Individual 1 agreed that
Individual 1 would assist defendant CHIANG and Project D in exchange
for future payment. Specifically, Individual 1 agreed to perform and
did perform official acts in his capacity as Deputy Mayor to benefit
Project D. In exchange, defendant CHIANG agreed to share consulting
fees and bonus payments from Company D with Individual 1, and
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provided approximately $112,000 directly and indirectly to
Individual 1 between October and December 2017.
a) Early Corrupt Relationship between Company D and
Councilmember A
32. In 2014, Company D, through its subsidiaries, acquired a
property located in CD-A for more than $100 million and planned a
massive redevelopment, Project D, that would include retail space,
residential units, and hotel rooms.
33. In or around January 2015, defendant CHIANG began working
as a consultant for Company D on Project D, earning approximately
$5,000 per month.
34. Beginning in early 2014, defendant CHIANG and Individual 1
facilitated the introduction of Councilmember A to Company D and
Chairman D. For example, on November 4, 2014, defendant CHIANG sent
an email to City Staffer A-1 with the subject line “[Councilmember A]
Fundraising,” writing: “Can you get me in touch with [Councilmember
A]? [Individual 1] and I had dinner with [Company D] last night
regarding pledging their support so I want to discuss this to prepare
the Councilman’s dinner with them this Thursday.”
35. In subsequent months, defendant CHIANG provided in-kind
contributions to Councilmember A’s re-election campaign, including
printers, stamps, and food.
36. On September 7, 2015, Individual 1, in his capacity as the
then General Manager of LADBS, communicated with Councilmember A and
defendant CHIANG regarding Project D. Specifically, Individual 1
sent a group text message to Councilmember A and defendant CHIANG,
writing: “Per our conversation a few days ago, I am sending you this
text message to suggest to you the names of the people whom you
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should invite to the biweekly [Company D]-Planning meeting. On
[Company D] side, [General Manager D], GEORGE CHIANG, (whom I include
in this text message), and [an attorney] should be invited. They may
bring others. On the Planning side, [a Planning official] should be
invited and you need to demand his presence. I am certain that he
would bring others. [A public official] represented the mayor's
office should also be invited. At your first meeting, please stress
that this will be a standing biweekly meeting until the TFAR matter
is determined. Please let me know if there is anything that I can be
is assistance. Best, [Individual 1].”
37. On September 8, 2015, defendant CHIANG sent a group text
message to Councilmember A and Individual 1, writing: “Dear
[Councilmember A] and [Individual 1], thank you for making this
arrangement possible. As the clock ticks, the chairman [D] is
beginning to feel weary about our progress. I just need to make sure
that he sees the light at the end of the tunnel. Once again, thank
you both for all of your support hopefully I can bring some good news
within the near future. Like always, please let me know if I can be
helpful. Thanks, GEORGE [CHIANG].”
38. In 2015, High School A planned a gala event and fundraiser
on September 18, 2015. In or around September 2015, at
Councilmember A’s direction, City Staffer A-1 solicited donations to
the high school gala event from developers and consultants with
projects pending in Councilmember A’s district, including a $10,000
contribution from Company D, which Company D paid.
39. In or around 2015 or 2016, Councilmember A, through City
Staffer A-1, asked defendant CHIANG to have Company D set up a
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monthly retainer with Law Firm A, from which Relative A-1 received
bi-weekly paychecks of approximately $2,500.
40. In approximately 2016, at a meeting that defendant CHIANG
attended, Councilmember A told Chairman D that there was no need to
involve the City’s Mayor in the approval process of Project D because
Councilmember A was the one in control of the PLUM committee.
Councilmember A stated that the City’s Mayor could not provide help
to Chairman D and it was Councilmember A who drove the project. In
addition, Councilmember A told defendant CHIANG privately to tell
Chairman D that as far as the success of Project D was concerned,
Chairman D did not need anyone else in the City but Councilmember A.
b) $66,000 Bribe to Councilmember A’s Associate in Exchange
for Motion
41. Between November 2015 and November 2016, Councilmember A
solicited financial benefits from Company D, including from defendant
CHIANG (its consultant), Chairman D, and General Manager D, in
exchange for Councilmember A’s official acts to benefit Project D.
Specifically, Chairman D and General Manager D agreed to provide
indirect financial benefits to Councilmember A in the form of
consulting fees to Councilmember A’s Associate in exchange for
Councilmember A introducing a motion to benefit Project D. Defendant
CHIANG facilitated part of this arrangement, as described further
below.
42. On November 11, 2015, defendant CHIANG and Councilmember A,
City Staffer A-1, Chairman D, and General Manager D met over dinner
at a restaurant in Arcadia, California. At the meeting, defendant
CHIANG translated for Councilmember A and Chairman D as they
discussed obtaining Councilmember A’s support for Project D. In
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addition, in the same conversation, Councilmember A asked Chairman D
to hire Councilmember A’s associate on Company D’s project. Chairman
D told Councilmember A to discuss the details with General Manager D.
43. On November 16, 2015, defendant CHIANG sent an email to
City Staffer A-1, copying General Manager D, confirming the new
agreement between Councilmember A and Chairman D. Defendant CHIANG
stated: “Now with a common consensus in place for [Project D], we
would like to roll this project full speed ahead. Therefore, I would
like to request the biweekly standing meeting to restart.... From
this point on, we would like to communicate all aspects of our
project with your [CD-A] office FIRST prior to any other offices in
the city family.... [P]lease be ready to coordinate with Mayor’s
office, Planning Department, and all other related parties so we can
drive on a singular track.”
44. On December 8, 2015, as part of this new agreement,
defendant CHIANG and Councilmember A met in person at a coffee shop
in Los Angeles to discuss a consulting agreement to pay
Councilmember A’s Associate. At the meeting, defendant CHIANG told
Councilmember A that General Manager D would work with Councilmember
A on retaining Councilmember A’s Associate. Councilmember A told
defendant CHIANG that Relative A-1 would be involved with getting the
retainer consummated.
45. Between December 8, 2015 and December 16, 2015, at a
meeting at the site of Project D, General Manager D asked defendant
CHIANG if defendant CHIANG’s consulting firm Synergy could hire
Councilmember A’s Associate if, in return, Company D would increase
the retainer with Synergy to cover that cost. Defendant CHIANG
declined.
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46. On December 16, 2015, defendant CHIANG facilitated an
introduction between Relative A-1 and Chairman D’s relative.
Relative A-1 met with Chairman D’s relative at a café in Pasadena,
California, to discuss an arrangement whereby Chairman D’s relative’s
company would pay a company affiliated with Councilmember A’s
Associate, purportedly for real estate advice.
47. On April 19, 2016, Councilmember A sent a text message to
defendant CHIANG, stating that Councilmember A “would like to briefly
speak with [General Manager D]” about an “[u]pdate on some of my
meetings with [Relative A-1].” Defendant CHIANG responded: “Let me
call [General Manager D] right now and get back to you.”
48. On April 26, 2016, Councilmember A sent a text message to
defendant CHIANG and asked: “Everything good?” Defendant CHIANG
responded, “Yes sir!” Councilmember A subsequently answered: “Cool.
The more I think about our project, the more I get excited about it.
Let’s meet every two weeks or so to see how things are going.... I
think it’ll be great!”
49. In May 2016, Company A and Chairman D’s relative’s company
executed an agreement whereby Company A would purportedly “provide
marketing analysis for Real Estate and Land Development Opportunities
in the Greater Southern California Area in the total amount of
$11,000.00 per month for services rendered. The term of this
agreement is one (1) year with one (1) option year.” In reality,
defendant CHIANG prepared the monthly marketing analysis reports and
delivered them to Councilmember A, who then provided them to
Councilmember A’s Associate, who collected the $11,000 monthly
retainer. Defendant CHIANG, Councilmember A, Chairman D, and General
Manager D understood that the monthly retainer payments were intended
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to be and were indirect bribe payments to Councilmember A in exchange
for Councilmember A’s official acts to benefit Project D.
50. On May 31, 2016, defendant CHIANG and Councilmember A had a
conversation via text message regarding Councilmember A obtaining the
monthly reports purportedly prepared by Company A (but in fact
prepared by defendant CHIANG) pursuant to the consulting agreement
with Chairman D’s relative regarding real estate and land development
opportunities.
Real Estate Report #1
51. On May 31, 2016, defendant CHIANG delivered to
Councilmember A his first real estate report that they intended would
be passed off as being created by Company A pursuant to its $11,000
per month consulting agreement with Chairman D’s relative.
52. Between May 31, 2016 and June 8, 2016, Councilmember A met
with Councilmember A’s Associate and delivered the first real estate
report he received from defendant CHIANG.
53. On June 8, 2016, Councilmember A’s Associate caused his
employee to send an email to Chairman D’s relative transmitting the
first report and first invoice for May 2016.
54. On June 15, 2016, pursuant to the consulting agreement,
Chairman D’s relative sent the first wire payment of $11,000 to
Company A, to a Union Bank account ending in 6345.
55. On June 23, 2016, Relative A-1 deposited $400 in cash into
her Bank of America account ending in 4340.
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Real Estate Report #2
56. On July 1, 2016, defendant CHIANG met with Councilmember A
at a coffee shop in Los Angeles, where defendant CHIANG delivered his
second real estate report.
57. On July 14, 2016, Councilmember A met with
Councilmember A’s Associate and delivered the second real estate
report he received from defendant CHIANG.
58. On July 14, 2016, Councilmember A’s Associate caused his
employee to send an email to Chairman D’s relative transmitting the
second report and second invoice for June 2016.
59. On July 19, 2016, pursuant to the consulting agreement,
Chairman D’s relative sent the second wire payment of $11,000 to
Company A, to a Union Bank account ending in 6345.
Real Estate Report #3
60. On August 1, 2016, defendant CHIANG met with
Councilmember A at a restaurant in Los Angeles, where defendant
CHIANG delivered his third real estate report.
61. On August 10, 2016, Councilmember A met with
Councilmember A’s Associate at a restaurant and delivered the third
real estate report he received from defendant CHIANG.
62. On August 11, 2016, Councilmember A’s Associate caused his
employee to send an email to Chairman D’s relative transmitting the
third report and third invoice for July 2016.
63. On August 16, 2016, Relative A-1 deposited $500 in cash
into her Bank of America account ending in 4340.
64. On August 17, 2016, pursuant to the consulting agreement,
Chairman D’s relative sent the third wire payment of $11,000 to
Company A, to a Union Bank account ending in 6345.
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Real Estate Report #4
65. On September 2, 2016, defendant CHIANG met with
Councilmember A at a coffee shop in Los Angeles, where defendant
CHIANG delivered his fourth real estate report.
66. On September 8, 2016, Councilmember A met with
Councilmember A’s Associate and delivered the fourth real estate
report he received from defendant CHIANG.
67. On September 8, 2016, Councilmember A’s Associate caused
his employee to send an email to Chairman D’s relative transmitting
the fourth report and fourth invoice for August 2016.
68. On September 9, 2016, pursuant to the consulting agreement,
Chairman D’s relative sent the fourth wire payment of $11,000 to
Company A, to a Union Bank account ending in 6345.
69. On September 15, 2016, Relative A-1 deposited $500 in cash
into her Bank of America account ending in 4340.
Real Estate Report #5
70. On October 4, 2016, defendant CHIANG met with
Councilmember A at Councilmember A’s residence, where defendant
CHIANG delivered his fifth real estate report.
71. On October 14, 2016, Councilmember A met with
Councilmember A’s Associate over breakfast and delivered the fifth
real estate report he received from defendant CHIANG.
72. On October 14, 2016, Councilmember A’s Associate caused his
employee to send an email to Chairman D’s relative transmitting the
fifth report and fifth invoice for September 2016.
73. On November 9, 2016, Relative A-1 deposited $800 in cash
into her Bank of America account ending in 4340.
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74. On November 14, 2016, pursuant to the consulting agreement,
Chairman D’s relative sent the fifth wire payment of $11,000 to
Company A, to a Union Bank account ending in 6345.
Real Estate Report #6
75. On November 3, 2016, defendant CHIANG met with
Councilmember A at a coffee shop in Los Angeles, where defendant
CHIANG delivered his sixth and final real estate report.
76. On November 3, 2016, Councilmember A met with
Councilmember A’s Associate and delivered the sixth real estate
report he received from defendant CHIANG.
77. On November 22, 2016, Councilmember A, in his official
capacity, presented a written motion in the Economic Development
committee to benefit Project D.
78. On November 23, 2016, Councilmember A’s Associate caused
his employee to send an email to Chairman D’s relative transmitting
the sixth report and sixth invoice for October 2016.
79. On November 30, 2016, pursuant to the consulting agreement,
Chairman D’s relative sent the sixth wire payment of $11,000 to
Company A, to a Union Bank account ending in 6345.
80. On December 2, 2016, Relative A-1 deposited $1,000 in cash
into her Bank of America account ending in 4340.
81. On December 6, 2016, Relative A-1 deposited $500 in cash
into her Bank of America account ending in 4340.
82. On December 9, 2016, defendant CHIANG and Councilmember A
met to discuss Councilmember A’s filing of the Project D motion in
exchange for retainer fees facilitated by defendant CHIANG, Chairman
D, and General Manager D to Councilmember A’s Associate.
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83. On December 10, 2016, defendant CHIANG and Individual 1
discussed not disclosing that defendant CHIANG had told Individual 1
the arrangement Councilmember A had with Company D. Specifically,
defendant CHIANG sent a text message to Individual 1, writing:
“please don’t tell [Councilmember A] [I] told you about the meeting I
had with him. He told me not to tell anyone even [City
Staffer A-1].”
84. On December 13, 2016, the City Council adopted the Project
D motion Councilmember A presented. Councilmember A voted “yes” on
the matter in City Council.
85. On December 13, 2016, defendant CHIANG, Councilmember A,
and General Manager D met at the site of Project D to discuss Project
D and Councilmember A’s agreement to expedite the project going
forward.
86. On December 21, 2016, Relative A-1 deposited $500 in cash
into her Bank of America account ending in 4340.
c) Additional Benefits to Councilmember A and Other Officials
in Exchange for Official Acts
87. In or around April 2017, at Councilmember A’s request,
defendant CHIANG organized and coordinated a trip for Councilmember A
and his family members to visit Chairman D in China. Defendant
CHIANG coordinated and paid approximately $500 for visa fees, and
arranged for transportation for Councilmember A and his family in
Hong Kong.
88. Between April 15, 2017 and April 23, 2017, Councilmember A
and his family visited Chairman D in Hong Kong and China. Chairman D
paid for certain transportation, meals, and lodging for
Councilmember A and his family members.
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89. On April 27, 2017, at Councilmember A’s request, defendant
CHIANG provided concert tickets to Councilmember A worth
approximately $1,572.
90. On May 2, 2017, in a telephone call, defendant CHIANG and
City Staffer A-1 discussed the mutually beneficial financial
relationship between Chinese developers and Councilmember A and
Individual 1. Specifically, City Staffer A-1 told defendant CHIANG:
“Looking from your perspective, you bank on [Individual 1], and
[Councilmember A]’s office to do, one of the main points with
[Councilmember A], for your Chinese clients for example,
‘entitlements, PLUM,’ you got to use that and we gotta keep making
his motherfucking, him happy.”
91. On May 3, 2017, in a telephone call, defendant CHIANG and
City Staffer A-1 discussed the possibility of law enforcement
detecting their bribery schemes. City Staffer A-1 stated: “If shit
does hit the fan, it’s like, ‘Hey man, we were all told,
[Councilmember A] told us to do it.’” Defendant CHIANG responded: “I
understand that, but we can really be [Councilmember A]’s accessories
because the first thing he is going to do is throw all the dirt on
you.”
92. On May 10, 2017, in a telephone call, City Staffer A-1 told
defendant CHIANG: “So today we had a productive day where
[Councilmember A] told [City Staffer A-2], let’s streamline the
[Company D] project.”
93. On May 10, 2017, in a telephone call, City Staffer A-1 told
defendant CHIANG: “[Councilmember A’s] approach is that he’s going to
um, strong arm everyone ... to the PAC. [Company D], [another
company]. ‘This is what I want right now. This is my wife, this is
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what we are doing.’ So his idea in his mind is that okay, people are
going to support us because they don’t want people to fuck with
projects, you know.”
94. On May 13, 2017, via a text message conversation,
Councilmember A expressed his eagerness to benefit Chairman D in
connection with Project D. Councilmember A wrote to defendant
CHIANG: “But the 2 tower is better for chairman [D] and his choice?
[Because] if he wanted the 3 towers and that is the best choice, we
can make that happen.”
95. On May 19, 2017, at Councilmember A’s request, defendant
CHIANG paid approximately $1,000 for alcohol for a party for
Councilmember A’s relative.
96. On May 21, 2017, City Staffer A-1 requested event tickets
from defendant CHIANG for City Staffer A-2, who had been working on
Project D. Specifically, City Staffer A-1 wrote: “Also, can we
please work on three tickets for lakers? Any game. Want to take
care of [City Staffer A-2]. I can let [City Staffer A-2] know u were
the one getting him 4 tickets.” On May 22, 2017, defendant CHIANG
purchased four Lakers tickets for approximately $630, and
subsequently gave the tickets to City Staffer A-1 to provide to City
Staffer A-2.
97. On June 11, 2017, in a telephone call, defendant CHIANG and
City Staffer A-1 again discussed the possibility of law enforcement
detecting their bribery schemes. City Staffer A-1 stated:
“[E]veryone already knows man, if [Councilmember A] gets busted,
which most likely he will, he’ll be like, ‘[City Staffer A-1] did
it,’ or ‘[Businessperson A] did it,’ or, you know, ‘[another person]
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did it,’ or ‘Chairman did it.’” In response, defendant CHIANG stated
that “for everybody to kind of be part of it is dangerous.”
98. On June 19, 2017, at Councilmember A’s request, defendant
CHIANG provided concert tickets to Councilmember A worth $1,670.
99. On June 23, 2017, in a telephone call, defendant CHIANG and
Kim discussed using Councilmember A’s influence as a councilmember
going forward and Councilmember A’s requests for financial benefits.
Specifically, Kim stated: “this is my agenda, not only do I want to
make money, GEORGE [CHIANG], I want to show you and other Chinese
developer, assuming [Councilmember A] is there, how much motivation
he’s going to have to push everything around for my project, those
are my agenda.” In response, defendant CHIANG asked if
Councilmember A understood “what he needs to do in three and a half
years.” Kim replied: “Yes, yes. Everything is set. You’re gonna see
some differences, alright GEORGE?” Defendant CHIANG then asked to
meet with Kim, stating that Councilmember A was asking for “some very
stupid requests.” Kim responded: “I’m not going to make a comment,”
to which defendant CHIANG stated: “Yeah, let’s not talk about this on
the phone.”
100. On August 24, 2017, defendant CHIANG again asked for
Councilmember A’s help on Project D. Specifically, defendant CHIANG
sent a text message to Councilmember A, writing: “Hi Boss, wanted to
give you heads up: [A Company D employee] spoke to chairman [D] and
CPC [City Planning Commission] needs to be 9/14/17 otherwise the loan
commitment from lender will be lost for the project.” The next day,
defendant CHIANG again sent a message to Councilmember A, writing:
“Hi Boss, we met with planning yesterday and went through the
outstanding items for 9/14/17 CPC. We would need a motion from your
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office to direct the TFAR allocation by next week before council
recess to make the 9/14/17 CPC hearing.”
101. On August 24, 2017, in a telephone call, defendant CHIANG
told Individual 1: “Do or die, because if we lose the September 14
[CPC hearing date], then we lose all loan commitments from the lender
... you know, probably not looking at a project.” Individual 1
responded: “You mentioned to [Councilmember A] this is a big issue.”
Defendant CHIANG responded: “Yes, yes, I did, I told him ... the
motion is very important in order for us to move forward.... We all
spoke to the Chairman [D], and the Chairman [D] is willing to make a
lot of sacrifices.”
102. On September 1, 2017, at defendant CHIANG’s request,
Councilmember A presented a written motion in the PLUM committee to
benefit Company D, allowing Project D to move forward with its
application and approval process before the CPC and City Council.
103. On September 1, 2017, Councilmember A notified defendant
CHIANG that Councilmember A held up his end of the bargain to help
Company D. Specifically, Councilmember A wrote to defendant CHIANG
in a text message: “We got the motion in today.”
104. In or around September 2017, Councilmember A used his
official position to pressure other officials, including officials in
the Planning Department and in the Mayor’s office, to influence the
approval of Project D by the CPC.
105. On September 14, 2017, Councilmember A wrote to defendant
CHIANG in a text message: “Congrats. Yeah we [CD-A office] were
calling mayors office to tell his commission to calm down. It’s
expected from cpc they throw a lot of junk at projects these days.
Not over but make sure u relay to chairman [D] that we were helpful.”
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106. On September 14, 2017, in a telephone call, Councilmember A
told defendant CHIANG: “You know, whatever it was, we’ll fix it in
PLUM.... Did the boss [Chairman D], you call the boss [Chairman D]
already? ... Did you tell him that my office was helpful?” Defendant
CHIANG responded: “I told [Chairman D] everything.” Councilmember A
then stated: “Okay, cool, cool, cool. Good, good.... Do we have a
schedule for PLUM already?”
107. In or around November 2017, Councilmember A asked defendant
CHIANG to make a commitment on behalf of Company D to contribute
$100,000 to Relative A-1’s campaign in exchange for continued
favorable official acts by Councilmember A to benefit Project D.
Defendant CHIANG, on behalf of Company D, told Councilmember A he
could confirm Chairman D’s commitment of $100,000 to PAC A.
108. On December 5, 2017, the PLUM Committee, including
Councilmember A, voted to approve Project D.
109. On December 12, 2017, the City Councilmembers present at a
hearing voted to adopt the PLUM Committee report for Project D, which
approved the entitlements and allowed Company D to move forward in
the City approval process.
110. In early 2018, defendant CHIANG provided approximately $800
in cash to City Staffer A-1.
111. On January 24, 2018, defendant CHIANG, Chairman D,
Individual 1, Councilmember A, and Relative A-1 met for dinner at
Chairman D’s hotel in San Gabriel, California. At the dinner,
Chairman D pledged his commitment and support for Relative A-1’s
campaign for the CD-A seat.
112. On February 12, 2018, via a text message conversation,
Councilmember A and defendant CHIANG further confirmed the agreement
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to have Company D contribute to PAC A to benefit Relative A-1’s
campaign. Councilmember A wrote to defendant CHIANG: “fundraiser for
PAC will call u today.”
113. On March 9, 2018, Councilmember A submitted a resolution in
the PLUM Committee to benefit Company D, allowing Project D to move
forward in its approval process.
114. On March 20, 2018, the City Councilmembers present at a
hearing voted to adopt the Company D resolution submitted by
Councilmember A on March 9, 2018.
115. On March 29, 2018, defendant CHIANG and Councilmember A met
at Councilmember A’s residence to discuss Company D’s support and the
$100,000 contribution to the PAC to benefit Relative A-1’s campaign.
Later the same day, Councilmember A acknowledged defendant CHIANG’s
agreement to facilitate a contribution to Relative A-1’s campaign,
writing in a text message to defendant CHIANG: “Thanks again for all
your help.”
116. On April 23, 2018, defendant CHIANG wrote to Individual 1
via text message: “Below are items I’m talking to [Councilmember A]
about: 1) tell [Councilmember A] that [Chairman D] is coming in June,
we can talk about the PAC at that time.”
117. On April 23, 2018, defendant CHIANG and Councilmember A met
at Councilmember A’s residence to discuss Councilmember A’s continued
support for Project D in exchange for Company D’s agreement to
contribute $100,000 to PAC A to benefit Relative A-1’s campaign.
118. On May 18, 2018, defendant CHIANG and Individual 1 met with
Councilmember A for breakfast at a restaurant in Boyle Heights.
Councilmember A stated that he needed the PAC contribution as soon as
possible. Councilmember A stated he wanted the contribution now so
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that when Relative A-1 announced her candidacy, she would have money
to pour into the campaign and scare everyone else from running
against her. Councilmember A stated that other developers already
contributed in amounts of $50,000, $100,000, and $200,000.
119. On June 12, 2018, the City Council, including
Councilmember A, voted to approve the Development Agreement for
Project D. The same day, Councilmember A wrote to defendant CHIANG
in a text message: “Da [Development Agreement] for [Company D] just
passed council today. Does that mean project has been fully
entitled? Is that our last vote?”
120. On June 18, 2018, Councilmember A wrote to defendant CHIANG
in a text message: “When is the chairman [D] coming in to town? We
need to finalize pac stuff. Thanks.”
121. On July 30, 2018, the ordinance authorizing the execution
of the Development Agreement for Project D went into effect. The
same day, Councilmember A wrote to defendant CHIANG in a text
message: “any news on when [Chairman D] is coming in to town? Hoping
to catch dinner with him and talk about [Relative A-1] campaign.”
Defendant CHIANG responded: “Hi Boss, [Individual 1] is working on
it. I let you know after I see him in office tomorrow.”
122. On October 8, 2018, Councilmember A followed up regarding
Company D’s commitment to PAC A, writing to defendant CHIANG in a
text message: “Hey GEORGE [CHIANG]... have time to meet soon to tie
up some loose ends re the [Company D] project?”
123. On October 16, 2018, defendant CHIANG and Councilmember A
met at Councilmember A’s residence and discussed Company D’s
agreement to contribute to PAC A to benefit Relative A-1’s campaign,
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as promised, in exchange for Councilmember A taking multiple official
acts to benefit Project D.
d) Benefits to Individual 1 in Exchange for His Official Acts
124. In or around January 2017, while Individual 1 was the
Deputy Mayor for Economic Development, defendant CHIANG,
Individual 1, and Individual 1’s relative strategized to have
Synergy, defendant CHIANG’s consulting firm, take over navigating the
City approval process for Project D. Defendant CHIANG negotiated a
lucrative consulting contract with Company D that included a monthly
retainer of $35,000. The consulting contract was later modified to
include three significant milestone bonus payments: (1) $100,000 for
successfully completing a Planning Department advisory hearing in May
2017; (2) $150,000 for CPC approval in September 2017; and (3)
$185,000 for PLUM Committee and City Council approval in December
2017. Defendant CHIANG agreed with Individual 1 to pay a portion of
these fees to Individual 1, in exchange for Individual 1’s assistance
on Project D in Individual 1’s official capacity as Deputy Mayor. As
Deputy Mayor, Individual 1 exerted power over and influence on
various City departments, including the Planning Department and the
CPC.
125. On January 2, 2017, Individual 1 sent an email to defendant
CHIANG and Individual 1’s relative, with an attached chart depicting
“People Who Influence the Project.” The “Elected Officials” who
influenced the project included Councilmember A and others.
126. On January 13, 2017, defendant CHIANG, Individual 1, and
Individual 1’s relative discussed Synergy taking control of the City
approval process for Project D. Defendant CHIANG wrote in a group
text message: “met with chairman [D] again today. He had already
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instructed us to move forward on the project. I need to spend some
time and lay everything out. So I need to skip training tomorrow to
put my thoughts into context and send it to you and [Individual 1’s
relative]. Also, my retainer has been confirmed verbally so I need
[Individual 1’s relative] to modify it on paper for signature. Thank
you!” Individual 1 responded: “No problem. We should meet after you
put your thoughts together.”
127. On January 26, 2017, defendant CHIANG discussed Synergy
taking over Project D with Individual 1 and another consultant.
Specifically, defendant CHIANG wrote to Individual 1 and Synergy
Consultant in a text message: “everything went as planned. Chairman
[D] spent the first part of meeting yelling at everything about how
their current approach is wrong. Now Synergy takes full control.
Then he walked out. The meeting was productive.”
128. On February 3, 2017, defendant CHIANG sent a text message
to Individual 1, writing: “Meeting with chairman [D] was good report
to you tomorrow. Thank you!”
129. On February 8, 2017, Individual 1, using his power and
influence as the Deputy Mayor, coordinated a meeting between the
Deputy Planning Director and representatives of Company D, including
defendant CHIANG and Chairman D.
130. On or around March 13, 2017, Individual 1 used his official
position as the Deputy Mayor to pressure subordinate City officials
to take favorable official actions on Project D. Specifically, on
March 13, 2017, Individual 1 sent a group text message to defendant
CHIANG, Individual 1’s relative, and Synergy Consultant: “Hi [Synergy
Consultant], talked to [a Fire Department official] about travel
distance and tract map. He still help. Make sure we pay expedite for
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the the fire review of three tract map. [...] Still wait for [a
Transportation Department official] to call back.” Defendant CHIANG
responded: “Thank you [Brother]!” Synergy Consultant responded: “You
are the greatest...I will call [the Fire Department official] first.”
131. On March 28, 2017, defendant CHIANG informed Individual 1
about his negotiations with Company D on the Synergy consulting
payments, in which Individual 1 had a vested interest, specifically
the agreement to receive a portion of the consulting fees and bonus
payments. Specifically, defendant CHIANG wrote to Individual 1 in a
text message: “Last night I spoke to chairman [D] about late monthly
payment and stop of service he said it was all misunderstanding asked
me to go to [Company D] office this afternoon. Let me know if you
want to have meeting today? Completely up to you but I will drop by
regardless to drop everything off. Thank you!”
132. On March 28, 2017, Company D paid Synergy a monthly
retainer fee of $35,000 by check.
133. On March 28, 2017, Company D paid Synergy $46,666 by check
as back pay for monthly retainers for February 2017 and January 2017.
134. On May 11, 2017, Individual 1 reached out to Planning
Commission Official by text message from Individual 1’s personal cell
phone to Planning Commission Official’s personal cell phone.
Individual 1 requested a meeting with Planning Commission Official in
Hollywood, instead of Planning Commission Official’s office.
135. On May 12, 2017, Individual 1 and Planning Commission
Official met in Hollywood to discuss the upcoming CPC hearing for
Project D. Planning Commission Official had the ability to impose
requirements on Project D that would increase costs for Company D.
Planning Commission Official also needed to vote to approve the
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project at the CPC hearing. At the meeting, Individual 1, in his
capacity as Deputy Mayor, exerted pressure over a Mayor-appointed
public official to influence Planning Commission Official’s official
actions. Specifically, Individual 1 urged Planning Commission
Official to approve Project D. Individual 1’s motivation in
convincing Planning Commission Official to vote to approve the
project was to obtain a portion of defendant CHIANG’s consulting fees
from Company D for successfully reaching the CPC hearing benchmark.
136. On May 18, 2017, Company D issued a $100,000 check as the
first bonus payment to Synergy for successfully reaching the Planning
Department advisory hearing scheduled on May 24, 2017.
137. Consistent with his agreement to share the bonus payment
with Individual 1, defendant CHIANG asked Individual 1 if
Individual 1 wanted his share of the first bonus payment in check
form. Individual 1 told defendant CHIANG to wait until later and
that he preferred getting a bigger check at a later date.
138. On or around June 22, 2017, in a telephone call,
Individual 1 asked defendant CHIANG “when are you going to ... get
the cash for me for the 20 grand?” Defendant CHIANG responded, “I
got it sitting in the car,” referring to $20,000 cash. Individual 1
then instructed defendant CHIANG to “just keep it there for now.”
139. On June 30, 2017, Individual 1 retired from the City as a
public official.
140. On or around August 3, 2017, during the time in which City
laws prohibited Individual 1 from lobbying City officials, defendant
CHIANG, Individual 1, and City Staffer D, who worked as a staff
member for City Councilmember D, met at Individual 1 and defendant
CHIANG’s office to discuss Project D. Individual 1 asked City
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Staffer D to speak to Mayor Staffer 1 to ask Mayor Staffer 1 to put
pressure on the CPC to approve Project D. City Staffer D agreed to
do so.
141. On or about August 8, 2017, Individual 1 had a meeting with
City Staffer D’s relative in downtown Los Angeles at the office of
CCC Investment. At the meeting, Individual 1 and City Staffer D’s
relative discussed an arrangement for a consulting agreement that
would pay City Staffer D’s relative.
142. On or about August 29, 2017, at Individual 1’s request,
defendant CHIANG executed a consulting agreement between CCC
Investment and City Staffer D’s relative. The consulting agreement
provided for compensation of $1,000 per month, effective September 1,
2017, for four consecutive months. At Individual 1’s request,
between October 2017 and December 2017, CCC Investment ultimately
paid City Staffer D’s relative approximately $2,000 for “consulting
services.”
143. On August 11, 2017, during the time in which City laws
prohibited Individual 1 from lobbying City officials, Individual 1
discussed the plan for Individual 1 and defendant CHIANG to “run[]
the show” on Project D. Specifically, Individual 1 sent a group text
message to defendant CHIANG and Synergy Consultant: “Good morning
[Synergy Consultant], can you please email me whatever you have
drafted on our proposal in handling the permits for Company D?
GEORGE [CHIANG] and I may talk to Chairman [D] today. The purpose is
just to convince him that we will be the one running the show.”
144. On August 19, 2017, Individual 1 texted defendant CHIANG:
“Working on a 1 pager, in English and Chinese, that layouts all the
departments, permits, and clearances for the [Company D] project.
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Chairman [D].” Individual 1 then added: “To show the complexity of
our work. Will be done tomorrow. Then you revise and w chat to him.
That will be our tool for discussion.”
145. On September 13, 2017, in a telephone call, Individual 1
confirmed that he worked on Project D as Deputy Mayor and that he was
prohibited from appearing at the CPC hearing for the project.
Specifically, an associate asked Individual 1: “Are you going to the
CPC meeting tomorrow for [Company D]?” Individual 1 replied: “No,
no, absolutely not. You know this is right now I’m not really
involved with that part. Because that part they started when I was
still in the Mayor’s office. Because I cannot, I cannot.”
146. On September 14, 2017, in a telephone call, Individual 1
confirmed that he worked on Project D for the prior nine months,
including while serving as Deputy Mayor. Specifically, Individual 1
told an associate: “Oh my God, you know we were, we were working so
hard the last nine months. This is big, this is [Company D], this is
$700 million project, man, I’m telling you.” The associate replied:
“[Chairman D] better really treat you well when you go to visit him.”
Individual 1 responded: “Let’s put it this way, we are good, but
we’re not cheap. Let’s put it this way, the check is coming, that’s
the huge thing, okay?”
147. On September 14, 2017, Individual 1 confirmed that
Individual 1 influenced Company D’s CPC approval and that
Individual 1 expected a second bonus payment from Company D, in the
form of a portion of defendant CHIANG’s bonus, for reaching the
second CPC hearing milestone. Specifically, after the CPC approval,
Individual 1 sent a text message to his relative, writing: “CPC
approved [Project D]! We are moving on to PLUM.” Individual 1’s
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relative responded: “Good news for milestones,” referring to the
bonus payments. Individual 1 then wrote: “[Mayor Official 1] and
[Mayor Official 2] talked to the commissioners. [City Staffer D]
asked [Mayor Staffer 1]. You know who asked [City Staffer D].”
Individual 1’s relative responded: “Congrats!” Individual 1
answered: “To all of us! Still waiting for the 2nd payment.”
148. On September 14, 2017, in a telephone call, Individual 1
told an associate: “The big job, the [Company D] job, they approved
it in Planning Commission, but we were so worried because there is,
there’s a thick head, who is the uh, who’s the president of the
Commission. And uhhh, luckily, we use, we pull all the political,
you know, chains, we got the Council, we got the Mayor’s office,
talked to him and so, so you know, he modified the conditions a
little bit but it’s still good, okay. So we’re very happy, very
happy.” The associate replied: “In LA does it mean that it still has
to go to the Council?” Individual 1 responded: “It has to go to
PLUM, is the Planning and Land Use Committee, which is a Council
Committee, and then go to Council, but those are easy, those are all
good brothers, okay? This is the toughest one.”
149. On October 19, 2017, Company D issued a $150,000 check as
the second bonus payment to Synergy for Project D successfully
completing the CPC hearing on September 14, 2017.
150. On December 14, 2017, Company D issued a $185,000 check as
the third bonus payment to Synergy for Project D successfully
completing the PLUM hearing on December 5, 2017, and the City Council
hearing on December 12, 2017.
151. Between January 2017 and December 2017, Company D paid
Synergy approximately $772,536 in consulting fees and bonuses for its
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work on Project D. During that time period, Synergy paid
Individual 1’s Company $93,939.97, and Individual 1’s relative
$19,000. This approximately $112,000 paid by defendant CHIANG
through Synergy indirectly to Individual 1 was in exchange for
Individual 1’s actions in shepherding Project D through the various
City approval processes while Individual 1 was Deputy Mayor.
NICOLA T. HANNA United States Attorney
BRANDON D. FOX Assistant United States Attorney Chief, Criminal Division
MACK E. JENKINS Assistant United States Attorney Chief, Public Corruption and Civil Rights Section
VERONICA DRAGALIN Assistant United States Attorney Public Corruption and Civil
Rights Section